ML20082Q639

Response to ASLB 831201 Memorandum & Order for Submittal of Evidence Not Yet Served Re Motions to Strike Testimony. Documents for cross-examination Encl

ML20082Q639
Person / Time
Site:	Limerick
Issue date:	12/07/1983
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20082Q632	List: ML20082Q630 ML20082Q639 ML20082Q648
References
NUDOCS 8312120289
Download: ML20082Q639 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 i (Limerick Generating Station, )

Units 1 and 2) )

APPLICANT'S SUBMITTAL PURSUANT TO THE MEMORANDUM AND ORDER RULING ON MOTIONS TO STRIKE TESTIMONY The Atomic Safety and Licensing Board's Memorandum and 1

Order Ruling on Motions to Strike Testimony (December 1, 1983) slip op. at 2, required that, to the extent that documents which any party would seek to introduce into evidence were not served at the time of the written direct testimony, and which were not known to be in the possession I of the Board and affected parties, they should be received l

by the Board and the affected parties no later than December 7, 1983. Applicant has served its direct testimony and made available for inspection and copying the references utilized l

by its witnesses as requested by intervenors.1/ As a

-1/ To ensure that there is no confusion, Applicant will seek to introduce into evidence the specific portions of the Final Safety Analysis Report and Environmental Report-Operating License Stage already identified in the testimony of its witnesses.

1 8312120289 B31207 PDR ADDCK 05000352 O PDR ,

I convenience to the Licensing Board, Applicant is hereby submitting to it documents which might be used in cross-examination. This material is an extension of the Applicant's cross-examination plans and is therefore not being transmitted to the parties.

Resp;ctfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn Counsel for Philadelphia Electric Company December 7, 1983 l

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I.AW OFFICES GONNER & WETTERHAHN. P.G.

1747 PENNSYLVA!!!A AVENUE. N.W.

MA2E d WET MANN WAS HINGTON. D. C. 20006 nosEmTM,mADER

[".[,7,*, o o',*,," .. December 7, 1983 ROEERT N. PUBL (209)800-0500 or cotusst

~ ""$d.' Frank R. Romano ABLE ADDRESS: ATOM LAW

61. Forest Avenue

, Ambler, Pennsylvania 19002 4

In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353

Dear Mr. Romano:

As we discussed today, enclosed is " Applicant's Answers to Intervenor AWPP's First Set of Interrogatories on Quality

Assurance Assurance / Control" propounded by you on November 11, 1983. This request has been designated " Discovery 15."

As we also discussed, I am sending you this document in anticipation of the receipt of the Protective Agreement which I understand you executed and mailed out today in substantially the form as the one I sent you on December 1, 1983, with the one addition upon which we had agreed. I will serve that document on the Board and other parties upon

! receipt.

In accordance with past practice, the documentary material responsive to your request will be made available for your inspection during normal business days from 9:00 a.m. to 4:30 p.m. at a room near Philadelphia Electric Company's headquarters. Please call Edward Cullen, Esq. at

! 215/841-4273 to make specific arrangements at least one day in advance in order to gain access to the documents. Any copies that you wish made of this material as the result of your review should be marked and copies will be made at the -

commercial rate of approximately 7C per page.

l Pursuant to its request (Tr. 4338), we are sending under separate cover one copy of all docurants made L available to you.to the Atomic Safety and Licensing Board.

Sincerely, l ..

Mark J. Wetterhahn Counsel for the Applicant l .MJW/dlf l Enclosure l cc: . Service List g  % #

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